The CAT NMS Plan currently requires Industry Members to provide Firm Designated IDs, Customer Account Information and Customer Identifying Information to the CAT.

As set forth in the CAT NMS Plan, a Firm Designated ID is a unique identifier for each trading account designated by Industry Members for purposes of providing data to the CAT, where each such identifier is unique among all identifiers from any given Industry Member for each business date.

Customer Account Information includes, but is not limited to:

• Account number (except in certain circumstances);
• Account type;
• Customer type;
• Date account opened; and
• Large Trader identifier, if applicable.

Customer Identifying Information means information of sufficient detail to identify a Customer, including, but not limited to, (a) with respect to individuals: name, address, date of birth, individual tax payer identification number (“ITIN”)/social security number (“SSN”), individual’s role in the account (e.g., primary holder, joint holder, guardian, trustee, person with the power of attorney); and (b) with respect to legal entities: name, address, Employer Identification Number (“EIN”)/Legal Entity Identifier (“LEI”) or other comparable common entity identifier, if applicable; provided, however, an Industry Member that has an LEI for a Customer must submit that Customer’s LEI in addition to other information of sufficient detail to identify a Customer.

In light of security concerns, however, the Operating Committee is analyzing alternative approaches to providing Customer information.